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Who must register under Foreign Influence Transparency Scheme (FITS)?

The applicability test for Register under Foreign Influence Transparency Scheme (FITS), computed across 35 industries, 9 business structures and 6 size bands.

Short answer: Only if

Applies only if you undertake lobbying or political communication on behalf of a foreign principal. Whether it applies turns on a fact that no industry, structure or size settles on its own.

What the obligation is

Persons undertaking activities on behalf of foreign principals in Australia must register with the AG's Department.

The Foreign Influence Transparency Scheme Act 2018 requires registration of persons undertaking 'registrable activities' on behalf of 'foreign principals' (governments, government-related entities, political organisations, individuals). Annual updates + transaction reporting.

The applicability test

Applies only if you undertake lobbying or political communication on behalf of a foreign principal. Whether it applies turns on a fact that no industry, structure or size settles on its own.

How the regulator frames it: Persons undertaking lobbying, communications, donor activity, disbursement of funds, or general political activities for foreign principals.

What triggers it: Commencing a registrable activity.

Jurisdiction: Commonwealth law, so the test is the same in every state and territory.

Which industries are in or out

Outcome across the 35 industries Rules Mate maps (35 of 35: no).

The answer is the same in every industry: no. Industry does not change who must comply.

Business structure and size

Structure does not change the answer across all industries: for every structure the answer is "no".

Size does not change the answer across all industries: at every size band the answer is "no".

Worked examples

Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:

  • Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires a trigger outside this questionnaire.

Answers that bring it into scope

Starting from a small or large professional services company that does not otherwise meet the test, each of these single facts changes the engine's answer:

  • The business is foreign-owned: it becomes worth checking, because it applies only if you undertake lobbying or political communication on behalf of a foreign principal.

When you need to check further

The engine shows this obligation as "check whether this applies" when a business has foreign ownership. It then applies only if you undertake lobbying or political communication on behalf of a foreign principal. That fact is not something Rules Mate can infer from industry, structure or size.

What you must do, and when

When due
Within 14 days of commencement; annual + on-change updates.
Frequency
Annual
Evidence to keep
FITS registration confirmation; activity records.
Status
Current
Priority
High

Penalty for not complying

Maximum penalty: Criminal penalties up to 5 years imprisonment for serious offences.

Criminal liability

Breaches can be prosecuted as criminal offences, not only civil contraventions.

Audit or assurance level

Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.

Where it sits in the corpus

Rules Mate tracks 6 published obligations tagged "transparency", 0 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 1 of those apply outright. This obligation is rated high priority and carries criminal liability, and is a annual obligation.

Regulator, legislation and tools

Foreign Influence Transparency Scheme Act 2018: Federal regime requiring registration of persons undertaking registrable activities on behalf of foreign principals.

Free tools that help with this obligation:

Questions

Who must register under Foreign Influence Transparency Scheme (FITS)?
Applies only if you undertake lobbying or political communication on behalf of a foreign principal. Whether it applies turns on a fact that no industry, structure or size settles on its own.
Do sole traders need to register under Foreign Influence Transparency Scheme (FITS)?
No. Across every industry and every size band, the engine's answer for a sole trader is: no.
Do businesses with 1–5 employees need to register under Foreign Influence Transparency Scheme (FITS)?
No (1–5 employees, turnover $100K–$1M).
When is "Register under Foreign Influence Transparency Scheme (FITS)" due?
Within 14 days of commencement; annual + on-change updates.

Related

Sources

Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.